NYDFS Issued a $100  million to Mashreqbank.  Enforcement takeaways:

–  Conduct is failing to implement an effective OFAC compliance program, submitting incomplete reports to NYDFS, and failing to report misconduct to NYDFS;

–  Conduct relates to violations of federal economic sanctions against Sudan
–  NYDFS previously penalized Mashreq Bank $40 million in 2018 for a deficient BSA/AML program;

–  No monitor imposed;

–  Parallel actions by OFAC and the Federal Reserve Board.

The enforcement action may be found here:  https://www.dfs.ny.gov/reports_and_publications/press_releases/pr20211109